Bruce Musico
From:Sent:To:Cc:Subject:Attachments:
Dan BarssWednesday, December 24, 2008 9:07 AMBruce MusicoKevin WilliamsFW: Letter from Vanessa E. Quinn Ref: NAPS IFR Open Items12-23-08 Letter Williams NAPS IFR Open ltems.pdf; 12-23-08 Letter Williams NAPS IFROpen Items Enclosure.pdf
For your action.
From: Dowgwillo, Theresa [mailto:[email protected]]Sent: Tuesday, December 23, 2008 2:52 PMTo: Kevin WilliamsCc: Dan Barss; Hammons, DarrellSubject: Letter from Vanessa E. Quinn Ref: NAPS IFR Open Items
Dear Mr. Williams:
Please find attached a letter to your attention from Vanessa E. Quinn, Chief, Radiological EmergencyPreparedness Branch, FEMA. The original has been sent to you via normal USPS mail delivery.
Please let me know if I can be of any assistance.
Thankfyou,
T. Reni DowgwifloExecutive AssistantRadiological Emergency Preparedness BranchTechnological Hazards DivisionNational Preparedness DirectorateDHS/FEMA(202) 212-2301 OfficeTheresa.Dowgwillo(,dhs.gov
1
U.S. Department of Homeland Security500 C Street, SW'Washington, DC 20472
FEMA
December 23, 2008
Mr. Kevin WilliamsChief, Licensing and Inspection BranchDivision of Preparedness and ResponseNuclear Security and Incident ResponseU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001
Ref: Interim Findings Report (IFR) for Open Items for the North Anna Power Station (NAPS)Unit 3 Combined License (COL) Application
Dear Mr. Williams:
Please find enclosed the IFR for Open Items for the NAPS COL application submitted by theRadiological Emergency Preparedness (REP) Program staff from our Region III Office. Thisenclosure serves as the deliverable for the completion of FEMA's portion of Phase II of the NAPSCOL application process. The status of emergency preparedness for offsite response for the NAPSwas determined based on the review of the following plans:
* The Commonwealth of Virginia Radiological Emergency Response Plan (COVRERP),Volume III
* The Commonwealth of Virginia Emergency Operations Plan Peacetime Disasters, May 2007.* The Commonwealth of Virginia Department of Health/Division of Radiological Health and
Safety Regulations, Emergency Response Plan, 2007 (without Appendix 17 StandardOperating Procedures).
* The Louisa County Radiological Emergency Response Plan (RERP), October 2006.• The Caroline County Radiological Emergency Response Plan (RERP), October 2006." The Hanover County Radiological Emergency Response Plan (RERP), October 2006.* The Orange County Radiological Emergency Response Plan (RERP), October 2006.* The Spotsylvania County Radiological Emergency Response Plan (RERP), October 2006.
The review of the offsite emergency plans resulted in evaluation findings for all of the planningstandards and associated criteria contained in NUREG-0654/FEMA-REP-1, Rev. 1, as amended, thatare Offsite Response Organization responsibilities. After a review of information provided by thelicensee's response to Phase I of the Request for Additional Information, (ratings by criterion), theratings were modified as follows:
" Planning Standard A: Adequate --corrections must be made.* Planning Standard B: N/A* Planning Standard C: Adequate -corrections must be made.
www.fema.gov
Mr. Kevin WilliamsDecember 23, 20008Page 2
* Planning Standard D: Adequate." Planning Standard E: Adequate -corrections must be made." Planning Standard F: Adequate -corrections must be made." Planning Standard G: Adequate.* Planning Standard H: Adequate --corrections must be made." Planning Standard I: Adequate - corrections must be made." Planning Standard J: Adequate - corrections must be made." Planning Standard K: Adequate - corrections.must be made.* Planning Standard L: Adequate - corrections must be made.• Planning Standard M: Adequate -corrections must be made.* Planning Standard N: Adequate - corrections must be made." Planning Standard 0: Adequate.* Planning Standard P: Adequate - corrections must be made.
Should you or members of your staff have any questions regarding this matter, please contactMr. Nathaniel Yates at (202) 212-2125 or Ms. Bonnie Sheffield at (202) 212-2120.
Sincerely,
Vanessa E. Quinn
ChiefRadiological Emergency Preparedness Branch
Enclosure: As stated
cc: D. Barss, NRCD. Hammons, FEMA Region III
INTERIM FINDINGS REPORT FOR OPEN ITEMS
On the Adequacy of OffsiteRadiological Emergency Response Planning and Preparedness
For theProposed North Anna Power Station Unit 3
December 16, 2008
Prepared by theFederal Emergency Management Agency
Preparedness, Training, and Exercises DirectorateExercises Division
TABLE OF CONTENTS
A. EXECUTIVE SUMMARY ................................................................ 1
B. INTRODUCTION .................................. ...................................... 1
1. General Characteristics of the North Anna Power Plant ............... 12. Emergency Response Organization ................................................... 13. P lans .................................................................................. . . 2
C. BASIS FOR FINDINGS ................................................................. 3
D. EVALUATION FORMAT .............................................................. 3
E. INTERIM FINDINGS ...................................................................... 4
F. SCHEDULE OF PENDING ACTIONS .............................................. 5
G. TECHNICAL REVIEW COMPOSITE SUMMARY ............................... 6
H. OPEN ITEMS ............................................................................. 8
ii
A. EXECUTIVE SUMMARY
On November 27, 2007, Dominion Virginia Power (Dominion) submitted a CombinedLicense Application (COL) to the U.S. Nuclear Regulatory Commission to construct andoperate Unit 3 of the North Anna Power Station (NAPS) facility located in LouisaCounty, Virginia, approximately 40 miles north-northwest of Richmond. Part 5 of theCOL application contained the proposed North Anna Power Station Unit 3 CombinedLicense Application Emergency Plan.
The two existing reactors at NAPS have been on-line since 1978 and 1980. FEMAgranted formal approval of the initial offsite response jurisdiction's (ORO's) RadiologicalEmergency Response Plans (RERPs) in February 1983 under 44CFR350.8. A qualifyingexercise, under the requirements of 44CFR350.9, was conducted on September 18, 1983.On September 2, 1987, FEMA completed its review of the alert and notification systeminstalled around NAPS and determined that the system is adequate to provide promptalerting and notification to the public in the event of an emergency at the site. Thisreview is of the current ORO's plans.
B. INTRODUCTION
1. General Characteristics of the North Anna Power Station
The North Anna Power Station (NAPS), consisting of approximately 1,856 acres, islocated in Louisa County on the southern shore of Lake Anna in central Virginia, 40miles northwest of Richmond, 38 miles east of Charlottesville, and 24 miles southwest ofFredericksburg.
The 10-mile plume Emergency Planning Zone (EPZ) includes Louisa, Carolina, Hanover,Orange and Spotsylvania Counties. While the 50-mile Ingestion Pathway Zone (IPZ)includes all or parts of Louisa, Hanover, Orange, Spotsylvania, Albemarle, Amelia,Buckingham, Chesterfield, Culpeper, Cumberland, Essex, Fauquier, Fluvanna,Goochland, Greene, Henrico, King George, King and Queen, King William, Madison,New Kent, Page, Powhatan, Prince William, Rappahannock, Richmond, Stafford andWestmoreland Counties in the Commonwealth of Virginia and Charles County in theState of Maryland. NAPS is owned and operated by Dominion Generation.
2. Emergency Response Organization
In the Commonwealth of Virginia, the implementation of protective actions beyond thesite boundary but within the 10-mile plume exposure EPZ and within the 50-mile IPZ isthe primary responsibility of the elected officials of the local governments. As time maybe a critical factor in providing protection against plume exposure, initial response isbased on the implementation of preplanned actions. Follow-up action will be taken on theadvice of the Virginia Emergency Operations Center (EOC) personnel based on theresults of evaluation and assessment of the accident. Local directors of emergencyservices may take independent and preemptive action to implement protective actions
Interim Findings Report For Open Items (North Anna Power Station) -1I-
within their jurisdictions. Jurisdictions implementing preemptive local protective actionswill ensure that the Virginia EOC and surrounding jurisdictions are fully informed of allactions and decisions.
The Virginia Department of Emergency Management (VDEM) will activate andcoordinate implementation of the State plan, to include assistance to local governmentsand coordination of emergency response actions of Federal and State agencies.
The Virginia Department of Health (VDH) will implement procedures to determineactual off-site radiation distribution to refine the projected dose. Based on thisassessment,. VDH will recommend protective actions to be taken. VDH will evaluate theradiological situation on a continuing basis from the time of initial notification until theradiological emergency is over. It will provide technical guidance and assistance relativeto actions required, as indicated by the situation.
Radiation assessment and coordination of protective actions within the IPZ will be theprimary responsibility of the VDEM and VDH in cooperation with the VirginiaDepartment of Agriculture and Consumer Services and the Virginia Department ofEnvironmental Quality, Water Division.
In the State of Maryland, the implementation of protective actions within the 50-mile IPZis the primary responsibility of the Secretary of the Department of the Environment withassistance provided by other state agencies and the local governments.
3. Plans
The Commonwealth of Virginia Radiological Emergency Response Plan (COVRERP) isVolume III of the Commonwealth of Virginia Emergency Operations Plan PeacetimeDisasters. Volume III includes the basic plan as well as the organization concepts andpolicies and establishes the assignments of emergency responsibilities for radiologicalemergencies. The Appendices and Annexes in Volume III also include operationalconcepts and procedures for specific emergency responsibilities for State departments.
Louisa, Caroline, Hanover, Orange, and Spotsylvania Counties maintain separateRadiological Emergency Response Plans (RERPs). The individual plans contain thecounty's concept of operations and policies. Appendices assign specific emergencyresponsibilities to local government agencies.
The North Anna Power Station Development of Evacuation Time Estimates, October2007 (report prepared by KLD Associates, Inc.), was also used in the review of the plans.
One county in the State of Maryland, Charles County, is in the 50-mile ingestionplanning zone for NAPS. The State of Maryland plan was provided for review onOctober 30,2008. The COL application's supplemental information included theexisting RERPs from the Commonwealth of Virginia (dated May 2007), Louisa County,Caroline County, Hanover County, Orange County, and Spotsylvania County (all dated
Interim Findings Report For Open Items (North Anna Power Station) -2-
October 2006). It also included the Evacuation Time Estimate (ETE) report prepared byKLD Associates, Inc., dated October 2007. The Emergency Response Plan (ERP), and aseparate NUREG-0654 Cross Reference, for the Virgifnia Department of Health/Divisionof Radiological Health (VDH/DRH) was provided, along with the Standing OperatingProcedures (Appendix 17) of the plan, and the State of Maryland RERP which extends tothe 50-mile Ingestion Planning Zone.
The materials listed above were the basis for the review. NUREG-0654/FEMA-REP-1,Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency ResponsePlans and Preparedness in Support of Nuclear Power Plants," amended March 2002, andits Supplements, the Interim REP Program Manual, dated August 2002, current FEMAguidance documents, and established industry practices were considered in making thedetermination as to the plans' adequacy.
C. BASIS FOR FINDINGS
The status of emergency preparedness for offsite response to possible incidents resultingfrom an accident at the NAPS has been determined based on:
Review of the Commonwealth of Virginia Radiological Emergency Response Plan(COVRERP), Volume III, The Commonwealth of Virginia Emergency Operations PlanPeacetime Disasters, May 2007.
* Review of the Commonwealth of Virginia Department of Health/Division ofRadiological Health and Safety Regulations, Emergency Response Plan, 2007(without Appendix 17 Standard Operating Procedures).
" Review of the Louisa County Radiological Emergency Response Plan (RERP),October 2006.
" Review of the Caroline County Radiological Emergency Response Plan (RERP),October 2006.
" Review of the Hanover County Radiological Emergency Response Plan (RERP),October 2006.
* Review of the Orange County Radiological Emergency Response Plan (RERP),October 2006.
" Review of the Spotsylvania County Radiological Emergency Response Plan(RERP), October 2006.
D. EVALUATION FORMAT
In accordance with the FEMA/NRC Memorandum of Understanding dated June 17,1993, FEMA has agreed to furnish assessments, findings, and determinations as towhether State and local emergency plans and preparedness are adequate and capable ofimplementation.
Guidance for review and development of radiological emergency response. plans iscontained in the document NUREG 0654/FEMA7REP-1, Rev. 1, "Criteria for Preparationand Evaluation of Radiological Emergency Response Plans and Preparedness in Support
Interim Findings Report For Open Items (North Anna Power Station) - 3 -
of Nuclear Power Plants," amended March 2002. NUREG-0654/FEMA-REP-l and itsSupplements, the Interim REP Program Manual, dated August 2002, current FEMAguidance documents, and established industry practices are considered in making thedetermination as to a plan's adequacy.
E. INTERIM FINDINGS
The review of the offsite emergency plans resulted in evaluation findings for all of theplanning standards and associated criteria contained in NUREG-0654/FEMA-REP- 1,Rev. 1, as amended, that are ORO responsibilities. Each planning standard and criterionwas rated as follows:
* Adequate: Plans are adequate and there is reasonable assurance that they can beimplemented with only limited or no corrections needed.
* Adequate - corrections must be made: Plans are adequate but before adetermination can be made as to whether they can be implemented, correctionsmust be made to the plans or supporting measures must be demonstrated (e.g.adequacy and maintenance of procedure, training, resource, staffing levels andqualifications, and equipment).
* Inadequate: Plans are inadequate and cannot be implemented until they arerevised to corrected deficiencies noted in the Federal review.
" N/A: The planning standard or criterion is not applicable to this ORO.
The initial review resulted in the following interim evaluation findings (ratings bycriterion) as follows:
* Planning Standard A: Adequate - corrections must be made.* Planning Standard B: N/A* Planning Standard C: Adequate -,corrections must be made.* Planning Standard D: Adequate.* Planning Standard E: Adequate - corrections must be made.* Planning Standard F: Adequate - corrections must be made.* Planning Standard G: Adequate - corrections must be made.* Planning Standard H: Adequate - corrections must be made.* Planning Standard I: Adequate - corrections must be made.* Planning Standard J: Adequate - corrections must be made.* Planning Standard K: Adequate - corrections must be made.* Planning Standard L: Adequate - corrections must be made.* Planning Standard M: Adequate - corrections must be made.* Planning Standard N: Adequate - corrections must be made.* Planning Standard 0: Adequate - corrections must be made.* Planning Standard P: Adequate - corrections must be made.
After a review of information provided by the licensee's response to Phase I of theRequest for Additional Information, (ratings by criterion) have been modified as follows:
Interim Findings Report For Open Items (North Anna Power Station) -4-
* Planning Standard A: Adequate -corrections must be made.* Planning Standard B: N/A* Planning Standard C: Adequate -corrections must be made.* Planning Standard D: Adequate.* Planning Standard E: Adequate -corrections must be made.* Planning Standard F: Adequate -corrections must be made.* Planning Standard G: Adequate.* Planning Standard H: Adequate -corrections must be made.* Planning Standard I: Adequate - corrections must be made.* Planning Standard J: Adequate - corrections must be made.* Planning Standard K: Adequate- corrections must be made.* Planning Standard L: Adequate - corrections must be made.
Planning Standard M: Adequate -corrections must be made.* Planning Standard N: Adequate - corrections must be made.* Planning Standard 0: Adequate.* Planning Standard P: Adequate - corrections must be made.
Adequacy of the NAPS COL Application Emergency Plan review for OROs is alsodependent on:
* Satisfactory resolution of the above evaluation results that are "adequate -corrections must be made."
" An adequate demonstration of the completion of the COL Application EmergencyPlanning Inspections, Tests, Analyses, and Acceptance Criteria as it relates toOROs.
* Satisfactory demonstration of plan implementation during a joint exercise with thelicensee and state and local governments, as described in 44CFR350.9, andutilizing NAPS Unit 3 facilities.
F. SCHEDULE OF PENDING ACTIONS
The Commonwealth of Virginia is awaiting the Qualifying Exercise of the offsite plansand procedures for the 2009 Surry Biennial Exercise scheduled for August 4, 2009. Atthat time, necessary plan changes will be incorporated and submitted for Open Itemsidentified in the Commonwealth of Virginia Plans. In addition, The Commonwealth ofVirginia is awaiting the Qualifying Exercise of the offsite plans and procedures for the2010 North Anna Biennial Exercise scheduled for July 20, 2010. At that time, necessaryplan changes will be incorporated and submitted for Open Items identified in theCommonwealth of Virginia Risk County Plans.
Interim Findings Report For Open Items (North Anna Power Station) -5 -
G. TECHNICAL REVIEW COMPOSITE SUMMARY
The following table and discussion present the results for each criterion based on reviewof information provided by the licensee's response to Phase I of the Request forAdditional Information (RAI's), supporting documents submitted electronically or hardcopy, or verified by means of a site visit from FEMA Region III to the Commonwealth ofVirginia and the licensee. Of the total 109 criteria, Sixty-Nine criteria are now classifiedas adequate, one criterion remains inadequate, and Thirty-Nine criteria remain asadequate - corrections must be made.
Interim Findings Report For Open Items (North Anna Power Station) -6-
G. Technical Review Composite Summaryfor Virginia and Risk County REP Plans in Support of North Anna COL
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Interim Findings Report For Open Items (North Anna Power Station) -7-
RAI Number Open Item Description State/County 1/County 2
NA 001 A
NA 001 B
NA 001 C
NA 001 D
NA 001 E
NA 001 F
NUREG-0654 Evaluation Criterion A.3 and C.4COVRERP Volume IIl, Basic Plan, Attachment 1Written Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of
Agreement, etc.
NUREG-0654 Evaluation Criterion A.3 and C.4Louisa County RERP NUREG-0654 Cross Reference
Written Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of
Agreement, etc
NUREG-0654 Evaluation Criterion A.3 and C.4Caroline County RERP NUREG-0654 Cross
Reference-Written Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of
Agreement, etc
NUREG-0654 Evaluation Criterion A.3 and C.4Hanover County RERP NUREG-0654 Cross
ReferenceWritten Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of
Agreement, etc
NUREG-0654 Evaluation Criterion A.3 and C.4Orange County RERP NUREG-0654 Cross
ReferenceWritten Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of
Agreement, etc
NUREG-0654 Evaluation Criterion A.3 and C.4Spotsylvania County RERP NUREG-0654 Cross
ReferenceWritten Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of
Agreement, etc
Commonwealth of Virginia
Louisa County
Caroline County
Hanover County
Orange County
Spotsylvania County
NA 003 A
NA 003 B
NUREG-0654 Evaluation Criteria E.2 and F.L.eLouisa County RERP, Appendix 2, ESF#2 -
Communications Procedures and Appendix 5, ESF5Emergency Management Procedure
The Procedure for Mobilizing Response Personnel foran ALERT Declaration are not Included in the RERP
NUREG-0654 Evaluation Criteria E.2 and F.l.eCaroline County RERP, Appendix 2, ESF#2 -
Communications Procedures and Appendix 5, ESF5Emergency Management Procedure
The Procedure forMobilizing Response Personnel foran ALERT Declaration are not Included in the RERP
Louisa County"
Caroline County
Interim Findings Report For Open Items (North Anna Power Station) -8-
RAI Number Open Item Description State/County I/County 2
NA 003 C NUREG-0654 Evaluation Criteria E.2 and F.l.e HanoverHanover County RERP, Appendix 2, ESF#2 -
Communications Procedures and Appendix 5, ESF5Emergency Management Procedure
The Procedure for Mobilizing Response Personnel foran ALERT Declaration are not Included in the RERP
NA 003 D NUREG-0654 Evaluation Criteria E.2 and F.1.e OrangeOrange County RERP, Appendix 2, ESF#2 -
Communications Procedures and Appendix 5, ESF5Emergency Management Procedure
The Procedure for Mobilizing Response Personnel foran ALERT Declaration are not Included in the RERP
NA 003 E NUREG-0654 Evaluation Criteria E.2 and F. 1.e Spotsylvania CountySpotsylvania County RERP, Appendix 2, ESF#2 -
Communications Procedures and Appendix 5, ESF5Emergency Management Procedure
The Procedure for Mobilizing Response Personnel for anALERT Declaration are not Included in the RERP
NA 004 A.1
NA 004 A.2
NA 004 B. I
NA 004.B.2
NUREG-0654 Evaluation Criterion E.5 and J.10.cIdentification of, Notification of, and Information
Dissemination to Special PopulationsLouisa County RERP, Appendix 8, Public Health
ESF Procedure,Does not Include Procedures on the Identification of
Special Needs Populations who are notInstitutionalized
NUREG-0654 Evaluation Criterion E.5 and J.10.cLouisa County RERP, Section VII.A.4, Organization,
Dept. of Social Services States,The Department will Assist in Managing the
Emergency Needs of Special Needs Individuals.Section VII.A.5 Organization, Department of Mental
Health and Mental Retardation, States that theDepartment will Maintain a List of Mentally
Handicapped Persons who Would Require AssistanceDuring a Radiological Emergency. The Procedure forNotifying this Population during an Emergency is not
Included in the RERP
NUREG-0654 Evaluation Criterion E.5 and J. 10.cCaroline County RERP, Appendix 8, ESF #8 - Public
Health ProcedureDoes not Include Procedure in the RERP for
Identifying Special Needs Populations who are notInstitutionalized
NUREG-0654 Evaluation Criterion E.5 and J. 10.cCaroline County RERP, Section VII.A.4
Organization, Appendix 8, ESF #8The Procedure for Notifying Special Needs
Populations within the 10-Mile EPZ During anEmercencv are not Included in the RERP
Louisa County
Louisa County
Caroline County
Caroline County
Interim Findings Report For Open Items (North Anna Power Station) -9-
RAI Number I Open Item Description I State/County I/County 2
NA 004 C. 1
NA 004 C.2
NA 004 D.1
NA 004 D.2
NA 004.E. I
NA 004.E.2
NUREG-0654 Evaluation Criterion E.5 and J.10.cHanover County RERP, Appendix 8, ESF #8, Public
Health ProcedureDoes not Include Procedure in the RERP for
Identifying Special Needs Populations who are notInstitutionalized
NUREG-0654 Evaluation Criterion.E.5 and J.10.cHanover County RERP, Section VII.A.4, Appendix 8,
ESF #8The Procedure for Notifying Special Needs
Populations within the 10-Mile EPZ During anEmergency are not Included in the RERP
NUREG-0654 Evaluation Criterion E.5 and J. 10.cOrange County RERP, Appendix 8
Does not Include Procedure in the RERP forIdentifying Special Needs Populations who are not
Institutionalized
NUREG-0654 Evaluation Criterion E.5 and J. I0.cHanover County RERP, Section VII.A.5
The Procedure for Notifying Special NeedsPopulations within the 10-Mile EPZ During an
Emergency are not Included in the RERP
NUREG-0654 Evaluation Criterion E.5 and J. I0.cSpotsylvania County RERP, Appendix 8, ESF #8
Does not Include Procedure in the RERP forIdentifying Special Needs Populations who are not
Institutionalized
NUREG-0654 Evaluation Criterion E.5 and J. I0.cSpotsylvania County RERP, Section VII.A.4,
Appendix 8, ESF #8The Procedure for Notifying Special Needs
Populations within the 10-Mile EPZ During anEmergency are not Included in the RERP
Hanover County
Hanover County
Orange County
Orange County
Spotsylvania County
SpotsylvaniaCounty
NA 006 A NUREG-0654 Evaluation Criterion E.7 and J. 10.cThe COVRERP, Appendix 8, Potassium Iodide (KI)Administration, states that protective action decisions
regarding KI will be transmitted to the localGovernment Emergency Operations Centers and
broadcast to the general public using the EmergencyAlert System (EAS). It further states that VDEM willcoordinate news releases with VDH about KI and thatthe PIO will issue news releases regarding the use of
KI. None of the pre-scripted messages (either EAS ornews releases) found in Annex M, Public
Information, address the use of or distribution of KI.The County RERPs do contain sample news releaseswith this information. Provide pre-scripted messages,
(both EAS and news release) in the COVERERPabout the use of and distribution of KI.
Commonwealth of Virginia
Interim Findings Report For Open Items (North Anna Power Station) -10-
RAI Number Open Item Description State/County I/County 2
NA 011 A NUREG-0654 Evaluation Criterion H.4 Louisa CountyThe Louisa County RERP, Appendix 1, Emergency
Management ESF Procedures, states that uponopening an Evacuation Assembly Center (EAC), the
EOC is to notify all appropriate persons andorganizations. Appendix 3, Mass Care ESF.
Procedures, says that the EAC Supervisor is to notifyEAC staff. The notification procedures are not
specified, nor are the staffing organizations prior tothe required positions. Provide notification and
activation information for the EACs.
NA 011 B Same as RAI 011 A Caroline County
NA 011 C Same as RAI 011 A Hanover County
NA 011 D 'Same as RAI 011 A Orange County
NA 011 E Same as RAI 011 A Spotsylvania County
NA 013 A NUREG-0654 Evaluation Criterion H. 11 Commonwealth of VirginiaThe Commonwealth of Virginia RERP, Appendix 7,Tab E, Radiological Exposure Control, RadiologicalMonitoring Equipment Issued to Local Governments,lists the quantities of thermo luminescent dosimeters,
self-reading dosimeters, survey meters, and portalmonitors in each local jurisdiction. There is no
information about protective equipment,communications equipment, or emergency supplies.
Provide information on emergency equipment
NA 013 B Same As RAI 013 A Louisa County
NA 013 C Same As RAI 013 A Caroline County
NA 013 D Same As RAI 013 A Hanover County
NA 013 E Same As RAI 013 A Orange County
NA 013 F Same As RAI 013 A Spotsylvania CountyNA 014 A NUREG-0654 Evaluation Criterion 1.8 Commonwealth of Virginia
Field Monitoring TeamsThe Virginia Department of Health/Division of
Radiological ERP, Appendix 1, TaskProvide specific field monitoring procedures,including activation, notification means, field
team composition, transportation,communication, monitoring equipment and
estimated deployment times.
Interim Findings Report For Open Items (North Anna Power Station) -11 I-
RAI Number Open Item Description State/County 1/County 2
NA 015 A NUREG-0654 Evaluation Criterion 1.9 Commonwealth of VirginiaAir Sampling Procedures
The COVRERP, Appendix 6, Accident Assessment,and Virginia Department of Health/Division of
Radiological Health (VDH/DRH) ERP, Appendix 5,Accident Assessment Provide specific field
monitoring procedures for air sampling that ensurethe capability to detect radioiodine at the required
levelNA 016 A NUREG-0654 Evaluation Criterion 1. 10 Commonwealth of Virginia
Dose AssessmentThe Virginia Department of Health/Division of
Radiological Health (VDH/DRH) ERP,Appendix 5, Accident Assessment
VDH/DRH personnel.No procedures for estimating integrated dose from the
projected and actual dose rates and for comparingthese estimates with the protective action guides were
provided for review. Provide procedures for doseassessment and EPA PAG comparisons
NA 017 A.1 NUREG-0654 Evaluation Criterion J.2 Commonwealth of VirginiaOnsite Personnel Evacuation AssistanceThe Commonwealth of Virginia RERP,
Appendix 5 Emergency ResponseProvide information on the
assistance that will be provided to NAPS duringan onsite evacuation
NA 017 A.2 NUREG-0654 Evaluation Criterion J.2 Commonwealth of VirginiaOnsite Personnel Evacuation Assistance
The Commonwealth of Virginia RERP,Appendix 5 Emergency Provide
information identifying the remote assemblycenters
NA 017 B. 1 NUREG-0654 Evaluation Criterion J.2 Louisa CountyProvide information on the assistance that will be
provided to NAPS during an onsiteevacuation
NA 017 B.2 NUREG-0654 Evaluation Criterion J.2 Louisa CountyProvide information identifying the remote
assembly centers
Interim Findings Report For Open Items (North Anna Power Station) - 12-
RAI Number Open Item Description State/County 1/County 2
NA 018 A.1 NUREG-0654 Evaluation Criterion J.9 Commonwealth of VirginiaProtective Action Basis and Capability to Implement
The plans do not contain predetermined publicProtective Action Decisions (PADs) based on
Plant conditions. Provide information onpredetermined (PADs) based on plant
Conditions
NA 018 A.2 NUREG-0654 Evaluation Criterion J.9 Commonwealth of VirginiaProvide ingestion pathway decision-making
information including the title of theperson making decisions and what organization
will implement those decisions
NA 018 A.3 NUREG-0654 Evaluation Criterion J.9 Commonwealth of Virginia
COVRERP, Attachment 1, Supporting Plans,
Memoranda of Understanding; StandingOperating Procedures, and Public Affairs.
Publications, lists local governmentingestion pathway RERP plans as supporting
plans and directs the reader to Appendix 3,Tab E. There is no
Appendix 3, Tab E. Provide information prior tothe local government ingestion pathway
RERP plansNA 019 A.1 NUREG-0654 Evaluation Criterion J. 10.a Commonwealth of Virginia
The COVRERP, Appendix 5, Emergency Response,provides a map showing "Protective Action Zones"
(PAZs) around North Anna Power Station. However,the RERP does not include maps showing pre-
selected radiological sampling and monitoring points(including points for sampling water supplies), or thelocations of Evacuation Assembly Centers. Provide
maps showing pre-selected radiological sampling andmonitoring points (including points for. samplingwater supplies); and the locations of Evacuation
Assembly Centers
NA 019 A.2 NUREG-0654 Evaluation Criterion J. I0.a Commonwealth of VirginiaThe maps of evacuation routes and PAZs do not
clearly identify evacuation direction, roads, towns, orspecial facilities (such as schools). Provide
information that clearly identifies evacuationdirection, roads, towns, and special facilities on maps
Interim Findings Report For Open Items (North Anna Power Station) -13-
RAI Number I Open Item Description { State/County I/County 2
NA 019 B.1
NA 019 C
NA 019 D
NA 019 E
NA 019 F
NUREG-0654 Evaluation Criterion J.10.aThe Louisa County RERP, Appendix 3, Mass CareESF Procedure, does not have the road names and
other details in the emergency public bus route mapslarge enough to be legible. Provide emergency
public bus route maps with road names and otherdetails that are large enough to be legible
NUREG-0654 Evaluation Criterion J.10.aThe Caroline County RERP does not include mapsspecifying the locations of Evacuation Assembly
Centers and does not clearly identify towns or specialfacilities. Provide maps specifying the locations of
Evacuation Assembly Centers and clearly identifyingtowns and special facilities
NUREG-0654 Evaluation Criterion J. 10.aThe Hanover County RERP does not include mapsspecifying the locations of Evacuation Assembly
Centers and does not clearly identify towns o'r specialfacilities. Provide maps specifying the locations of
EvacuationAssembly Centers and clearly identifyingtowns and special facilities
NUREG-0654 Evaluation Criterion J.10.aThe Orange County RERP does not include mapsspecifying the locations of Evacuation Assembly
Centers and does not clearly identify towns or specialfacilities. Provide maps specifying the locations of
Evacuation Assembly Centers and clearly identifyingtowns and special facilities
NUREG-0654 Evaluation Criterion J.10.aThe Spotsylvania County RERP does not include
maps specifying the locations of EvacuationAssembly Centers and does not clearly identify towns
or special facilities. Provide maps specifying thelocations of Evacuation Assembly Centers and clearly
identifying towns and special facilities
Louisa County
Caroline County
Hanover County
Orange County
Spotsylvania County
NA 023 A.1 NUREG-0654 Evaluation Criterion J. 10.fThe COVRERP, Appendix 8, Potassium Iodide (KI)
Administration, states that the State HealthCommissioner may recommend or advise KI to be
ingested by the general public and emergencyworkers when a dose assessment predicts a thyroid
exposure threshold of 5 rem or if an actualmeasurement of 5 rem is obtained offsite. In otherparts of the COVRERP, the threshold is incorrectly
listed as "25 rem CDE (thyroid)." Provide the correctthreshold (5 rem CDE, Thyroid) prior to therecommended ingestion of KI throughout the
COVRERP
Commonwealth of Virginia
Interim Findings Report For Open Items (North Anna Power Station) - 14-
RAI Number Open Item Description State/County I/County 2
NA 023 A.2 NUREG-0654 Evaluation Criterion J. I0 f Commonwealth of VirginiaThe Virginia Department of Health/Division of
Radiological Health ERP lists the administration ofKI dose limit for emergency workers as 5 rem CDE
thyroid in some locations and as 25 rem CDE thyroidin others. Provide the correct threshold (5 rem CDE,Thyroid) prior to the recommended ingestion of KI
throughout the plan
NA 023 B NUREG-0654 Evaluation Criterion J. I0.f Louisa CountyProvide the correct threshold
(5 rem CDE, Thyroid) prior to the recommendedingestion of KI throughout the plan
NA 023 C SAME AS RAI 023 B Caroline County
NA 023 D SAME AS RAI 023 B Hanover County
NA 023 E SAME AS RAI 023 B Orange County
NA 023 F SAME AS RAI 023 B Spotsylvania CountyNA 024 A N-UREG-0654 Evaluation Criterion J. I0.g Louisa County
"Means of Relocation"Provide information for determining the number ofpersons who may need assistance for each planning
area and provide updated information on thepermanent resident population data
NA 024 B SAME AS RAI 024 A Caroline County
NA 024 C SAME AS RAI 024 A Hanover County
NA 024 D SAME AS RAI 024 A Orange County
NA 024 E SAME AS RAI 024 A Spotsylvania CountyNA 025 B NUREG-0654 Evaluation Criterion J. I0.h Louisa County
Louisa County RERP, Section V.D, Situation,Protection Against the Hazard, Provide informationprior to the EAC address, capacity, and accessibility
NA 025 C NUREG-0654 Evaluation Criterion J.10.h Caroline CountyThe plan does not provide the addresses prior to theEACs, the capacities, and if they are accessible toindividuals with disabilities. Provide information
prior to the EAC address, capacities, and accessibility
NA 025 D NUREG-0654 Evaluation Criterion J. 10.h Hanover CountyThe plan does not provide the addresses prior to the
EACs, the capacities, and if they are accessible toindividuals with disabilities. Provide information
prior to the EAC address, capacities, and accessibility
Interim Findings Report For Open Items (North Anna Power Station) -15-
RAI Number Open Item Description State/County 1/County 2
NA 025 E. I NUREG-0654 Evaluation Criterion J.10.h Orange CountyThe plan does not provide the address prior to the
EAC, the capacity, and if it is accessible toindividuals with disabilities. Provide information
prior to the EAC address, capacity, and accessibility
NA 025 E.2 NUREG-0654 Evaluation Criterion J.10.h Orange CountyThis is not consistent with the State Plan which alsolists Orange County High School as an EAC prior to
the county and Patrick Henry High School in HanoverCounty as the host reception center for Louisa
County. Provide information identifying all EACsand host reception centers within the county
NA 025 F NUREG-0654 Evaluation Criterion J. 10.h Spotsylvania CountyThe plan does not provide the addresses prior to the
EACs, the capacities, and if they are accessibleindividuals with disabilities. Provide information
prior to the EACs addresses, capacities, andaccessibility
NA 026 A NUREG-0654 Evaluation Criterion J.10.i Commonwealth of Virginia"Evacuation Route Traffic Capacity"
Provide updated information in the plan toincorporate the revised ETE study and evaluatefactors that might limit the capability to effect a
timely, safe evacuation
NA 026 B NUREG-0654 Evaluation Criterion J. 10.i Louisa CountyProvide updated information in the plan to
incorporate the revised ETE study, including updatedcounty evacuation route maps, and evaluate factors
that might limit the capability to effect a timely, safeevacuation
Interim Findings Report For Open Items (North Anna Power Station) -16-
RAI Number Open Item Description State/County 1/County 2
NA 026 C NUREG-0654 Evaluation Criterion J. 10.i Caroline CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation
route maps, and evaluate factors that might limit thecapability to effect a timely, safe evacuation
NA 026 D NUJREG-0654 Evaluation Criterion J.l0.i Hanover CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation
route maps, and evaluate factors that might limit thecapability to effect a timely, safe evacuation
NA 026 E NUREG-0654 Evaluation Criterion J. 10.i Orange CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation
route maps, and evaluate factors that might limit thecapability to effect a timely, safe evacuation
NA 026 F NUREG-0654 Evaluation Criterion J. 10.i Spotsylvania CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation
route maps, and evaluate factors that might limit thecapability to effect a timely, safe evacuation
NA 027 A NUREG-0654 Evaluation Criterion J.10.k Louisa County"Evacuation Route Impediments"
Provide information referencing the resources available tobe used in clearing impediments
NA 027 B SAME AS RAI 027A Caroline County
NA 027 C SAME AS RAI 027A Hanover County
NA 027 D SAME AS RAI 027A Orange County
NA 027 E SAME AS RAI 027A Spotsylvania County
Interim Findings Report For Open Items (North Anna Power Station) - 17 -
RAI Number Open Item Description State/County 1/County 2
NA 028 A NUREG-0654 Evaluation Criterion J.10.1 Commonwealth of Virginia"Evacuation Route Time Estimates"
Provide updated information incorporating the new ETEstudy including revised population data and separate time
estimates prior to the special population groups
NA 028 B SAME AS RAI 028 A Louisa County
NA 028 C SAME AS RAI 028 A Caroline County
SAME AS RAI 028 ANA 028 D Hanover County
NA 028 E SAME AS RAI 028 A Orange County
NA 028 F SAME AS RAI 028 A Spotsylvania CountyNA 029 A.1 NUREG-0654 Evaluation Criterion J. 11 Commonwealth of Virginia
"Ingestion Pathway Protective Measures"The COVRERP does not contain the following: the
criteria for putting animals on stored feed; theidentification and description of procedures for detecting
contamination, for estimating the dose commitmentconsequences from the ingestion pathway and for
imposing protective measures; and maps showing generalcrop information, farms, dairies, food processing plants,watershed, water supply intake and treatment plants and
reservoirsNA 030 A NIUREG-0654 Evaluation Criterion J. 12 Louisa County
"Evacuee Monitoring and Registration"Provide information showing the portal monitoring
operability check complies with the standard
NA 030 B Caroline CountySAME AS RAI 030 A
NA 030 C SAME AS RAI 030 A Hanover County
NA 030 D SAME AS RAI 030 A Orange County
NA 030 E SAME AS RAI 030 A Spotsylvania County
Interim Findings Report For Open Items (North Anna Power Station) -18-
AAI Number Open Item Description State/County 1/County 2
NA 031 A
NA 031 A.2
NA 031 B
NA 031 C
NA 031 D
NA 031 E
NA 031 F
NUREG-0654 Evaluation Criterion K.3.aThe Virginia Department of Health/Division of
Radiological Health (VDH/DRH) ERP, Appendix 6,Radiological Exposure Control, lists the correct
Emergency Worker Exposure Limits in step 2. 1, butthen refers to incorrect limits in step 2.4. The
VDH/DRH ERP lists the exposure control ratio asinitially 2
Provide revisions to all sections of the plans to ensurethat all instances of the administrative exposure limitsare correct and that the appropriate exposure or doseunits and exposure control ratios are used throughout
the plans
NUREG-0654 Evaluation Criterion K.3.aThe Commonwealth of Virginia RERP, Tab B2 to
Appendix 7, Radiological Exposure Control, lists thecorrect administrative exposure limits. Tab G to
Appendix 7 lists incorrect limits. In addition, Tab B2to Appendix 7 incorrectly lists the "EPA Protective-Action Guidelines, Emergency Worker Exposure
Limits." Provide revisions to all sections of the plansto ensure that all instances of the administrative
exposure limits are correct and that the appropriateexposure or dose units and exposure control ratios are
used throughout the plans
SAME AS RAI 031 A.2
SAME AS RAI 031 A.2
SAME AS RAI 031 A.2
SAME AS RAI 031 A.2
SAME AS RAI 031 A.2
Commonwealth of Virginia
Commonwealth of Virginia
Louisa County
Caroline County
Hanover County
Orange County
Spotsylvania CountyNA 032 A
NA 032 B.1
NA 032 C. I
NA 032 D. I
NA 032 E.1
NA 032 F.1
NUREG-0654 Evaluation Criterion K.4"'Emergency Worker Dose Authorization"
There are numerous inconsistencies throughout the plans inexposure limits, exposure control ratios, and radiation units
[exposure (R) and dose (Rem)] as detailed in CriterionK.3.a. Provide information about the procedure to
authorize high exposure limits to emergency workers
SAME AS RAI 032 A
SAME AS RAI 032 A
SAME AS RAI 032 A
SAME AS RAI 032 A
SAME AS RAI 032 A
Commonwealth of Virginia
Louisa County
Caroline County
Hanover County
Orange County
Spotsvlvania County
Interim Findings Report For Open Items (North Anna Power Station) -19 -
RAI Number Open Item Description State/County I/County 2
NA 033 A NUREG-0654 Evaluation Criterion K.5.a Louisa County"Decontamination Action Levels"
Provide information on monitoring the interior ofemergency vehicles
NA 033 B SAME AS RAI 033 A Caroline County
NA 033 C SAME AS RAI 033 A Hanover County
NA 033 D SAME AS RAI 033 A Orange County
NA 033 E SAME AS RAI 033A Spotsylvania CountyNA 034 A.1 NUREG-0654 Evaluation Criterion K.5.b Louisa County
"Decontamination Material Control"Provide information on secured storage areas for
contaminated equipment
NA 034 A.2 NUREG-0654 Evaluation Criterion K.5.b Louisa CountyProvide information on the doffing of personal
protective clothing prior to the initial monitoring
NA 034 B. I SAME AS RAI 034 A. 1 Caroline County
NA 034 B.2 SAME AS RAI 034 A.2 Caroline County
NA 034 C. 1 SAME AS RAI 034 A. 1 Hanover County
NA 034 C.2 SAME AS RAI 034 A.2 Hanover County
NA 034 D.1 SAME AS RAI 034 A.lI Orange County
NA 034 D.2 SAME AS RAI 034 A.2 Orange County
NA 034 E.1 SAME AS RAI 034 A.2 Spotsylvania County
NA 034 E.2 SAME AS RAI 034 A.2 Spotsylvania CountyNA 035 B NUREG-0654 Evaluation Criterion L. 1 Louisa County
Provide information identifying the primary andback-up hospitals and support information
demonstrating that they have the capability forevaluation of radiation exposure and uptake,
including assurance that persons providing theseservices are adequately prepared to handle
contaminated individuals.
NA 035 C SAME AS RAI 035 B Caroline County
Interim Findings Report For Open Items (North Anna Power Station). - 20 -
RAI Number Open Item Description State/County 1/County 2
NA 035 D SAME AS RAI 035 B Hanover County
NA 035 E SAME AS RAI 035 B Orange County
NA 035 F SAME AS RAI 035 B Spotsylvania CountyNA 036 A NUREG-0654 Evaluation Criterion L.3 Commonwealth of Virginia
"Medical Services for Contaminated/InjuredPatients"
Provide relevant information prior to the list ofadditional hospitals including qualifications to handle
contaminated injured patients, equipment forradiological response capabilities, specific locations,and capacities for ambulatory and non-ambulatory
individuals.
NA 037 A NUREG-0654 Evaluation Criterion L.3 Louisa CountyProvide information about the transport of
contaminated injured members of the public.
NA 037 B SAME AS RAI 037 A Caroline County
NA 037 C SAME AS RAI 037 A Hanover County
NA 037 D SAME AS RAI 037 A Orange County
NA 037 E SAME AS RAI 037 A Spotsylvania CountyNA 038 A.1 NUREG-0654 Evaluation Criterion M. 1 Commonwealth of Virginia
"Recovery and Reentry Procedures"Provide information for relocating persons that were
not evacuated but may be in contaminated areas.
NA 038 A.2 NUREG-0654 Evaluation Criterion M. I Commonwealth of VirginiaAppendix 11, Decontamination, Re-Entry, Return andRecovery, states the VDH dose levels for determiningthe need to relocate populations which is contrary toFederal guidance (EPA 400-R-92-001 states that the50 year committed dose includes the first and second
year whereas the stated dose in the COVRERPexcludes the first and second years). Provide correct
information on the dose levels for determining theneed to relocate populations.
NA 038 A.3 NUREG-0654 Evaluation Criterion M. 1 Commonwealth of VirginiaAppendix 11, Decontamination, Re-Entry, Return and
Recovery, states that the decision to allow re-entryand return of evacuated individuals rests with the
Director of Emergency Services of the localjurisdiction affected. However, there are no decision-making procedures identified in any county plan thataddress allowing evacuated persons or households to
permanently return to an evacuation area. Provideinformation addressing procedures for evacuated
persons to permanently return to an evacuated area.
Interim Findings Report For Open Items (North Anna Power Station) -21 -
RAI Number Open Item Description State/County I/County 2
NA 038 B NUREG-0654 Evaluation Criterion M. 1 Louisa CountyThe Louisa County RERP does not include anyinformation about reentry and return. Provide
information consistent with the COVRERP Appendix11, Decontamination, Re-Entry, Return and
Recovery, which states that the decision to allow re-entry and return of evacuated individuals rests with
the Director of Emergency Services of the localjurisdiction affected.
NA 038 C SAME AS RAI 038 B Caroline County
NA 038D SAME AS RAI 038 B Hanover County
NA 038 E SAME AS RAI 038 B Orange County
NA 038 F SAME AS RAI 038 B Sp6tsylvania County
NA 039 A NUREG-0654 Evaluation Criterion M.3 Commonwealth of Virginia"Recovery Operations Notifications"
The COVRERP, Appendix 6, Accident Assessment,states that offsite emergency operations will becoordinated from the Virginia EOC. Provide
information specifying the means that will be used tokeep all involved response organizations informed of
the recovery phase activities or changes that mighttake place in the organizational structure.
NA 041 A.1 NUREG-0654 Evaluation Criterion N.2.a Commonwealth of Virginia"Communications Drills"
The Commonwealth of Virginia RERP, Appendix 13,Provide. information on which is the appropriate
frequency of communications drills.
NA 041 A.2 NUREG-0654 Evaluation Criterion N.2.a Commonwealth of VirginiaThe COVRERP does not specify a mechanism to
ensure that the content of the message is understood.Provide a mechanism to ensure that the content of themessage is understood during communications drills.
NA 041 B.1 NUREG-0654 Evaluation Criterion N.2.a Louisa CountyThe Louisa County RERP, Section XII, Training,
Drills, and Exercises, states that monthly drills willcheck the systems used for communications betweenState and local governments which is different thanthe daily drills specified in the Commonwealth of
Virginia RERP. Provide information on which is theappropriate frequency of communications drills.
NA 041 B.2 NUREG-0654 Evaluation Criterion N.2.a Louisa CountyThe Louisa County RERP does not specify a
mechanism to ensure that the content of the messageis understood, Provide a mechanism to ensure that
the content of the message is understood duringcommunications drills.
Interim Findings Report For Open Items (North Anna Power Station) - 22 -
RAI Number Open Item Description State/County 1/County 2
NA 041 C. 1 SAME AS RAI 041 BA I Caroline County
NA 041 C.2 SAME AS RAI 041 B.2 Caroline County
NA 041 D.I SAME AS RAI 041 B.1 Hanover County
NA 041 D.2 SAME AS RAI 041 B.2 Hanover County
NA 041 E.1 SAME AS RAI 041 B.1 Orange County
NA 041 E.2 SAME AS RAI 041 B.2 Orange County
NA 041 F. 1 SAME AS RAI 041 B. 1 Spotsylvania County
NA 041 F.2 SAME AS RAI 041 B.2 Spotsylvania CountyNA 042 A NUREG-0654 Evaluation Criterion N.2.c Louisa County
"Local Jurisdiction Participation in Medical EmergencyDrills"
The Louisa County RERP does not includinginformation on the conduct of medical emergency
drills and participation of local emergency responseorganizations for transport of contaminated injured
individuals (members of the public, not licenseeemployees). Provide information about the
participation of Louisa County medical transport
NA 042 B providers in the annual medical emergency drills Caroline County
NA 042 C SAME AS RAI 042 A Hanover County
NA 042 D SAME AS RAI 042 A Orange County
NA 042 E SAME AS RAI 042 A Spotsylvania County
SAME AS RAI 042 A
Interim Findings Report For Open Items (North Anna Power Station) - 23 -
RAI Number Open Item Description State/County 1/County 2
NA 043 A NUREG-0654 Evaluation Criterion N.5 Commonwealth of Virginia"Implementing Corrective Actions Identified at Drills
and Exercises"The Commonwealth of Virginia RERP, Appendix 13,
Training and Exercises, states the recommendedcorrective actions from drills and exercises will be
implemented; however, the details of this process arenot given. Provide information on the managementcontrol that has been established to ensure corrective
actions are implemented.
NA 043 B SAME AS RAI 043 A Louisa County
NA 043 C SAME AS RAI 043 A Caroline County
NA 043 D SAME AS RAI 043 A Hanover County
NA 043 E SAME AS RAI 043 A Orange County
NA 043 F SAME AS RAI 043 A Spotsylvania CountyNA 046 A NUREG-0654 Evaluation Criterion P. 1 Commonwealth of Virginia
"Training Requirement for Individuals Responsiblefor the Planning Effort"
The COVRERP, Appendix 13, Section II.E.5,Training and Exercises, Operational Concepts and
Procedures, Training, states that "Key planners willbe sent to the Radiological Emergency Planning
Course at the Emergency Management Institute."Key planners within the State Agencies are notidentified. Provide information about the keyplanners within the State Agencies that will be
provided the appropriate training.
Interim Findings Report For Open Items (North Anna Power Station) - 24 -
RAI Number Open Item Description State/County 1/County 2
NA 046 B NUREG-0654 Evaluation Criterion P. 1 Commonwealth of VirginiaProvide information on the identification of the "keyplanner" and what training that person will receive
NA 046 C Same as RAI 046 B Commonwealth of Virginia
NA 046 D Same as RAI 046 B Commonwealth of Virginia
NA 046 E Same as RAI 046 B Commonwealth of Virginia
NA 046 F Same as RAI 046 B Commonwealth of VirginiaNA 047 B NUREG-0654 Evaluation Criterion P.4 Louisa County
Provide information on how identified issues areincorporated into the update of the plans.
NA 047 C Same as RAI 047 B Caroline County
NA 047 D Same as RAI 047 B Hanover County
NA 047 E Same as RAI 047 B Orange County
NA 047 F Same as RAI 047 B Spotsylvania CountyNA 050 B NUREG-0654 Evaluation Criterion P.7 Louisa County
The Louisa County RERP, Table of Contents andSection XIV, Appendices, provide a listing of
Appendices which contain implementing proceduresidentified by emergency support function. It is not acomplete list since some procedures have references
to additional procedures. The list does not include thesection(s) of the plan to be implemented by each
procedure. Provide information on which section(s)
of the plan are implemented by the procedures.
NA 050 C SAME AS RAI 050 B Caroline County
NA 050 D SAME AS RAI 050 B Hanover County
NA 050 E SAME AS RAI 050 B Orange County
NA 050 F SAME AS RAI 050 B Spotsylvania County
NA 051 A.1 NUREG-0654 Evaluation Criterion P.8 Commonwealth of VirginiaThe Commonwealth of Virginia RERP contains both
a Table of Contents and a NUREG-0654 CrossReference. The Table of Contents is thorough and
accurate. The NUREG-0654 Cross Reference has areference for almost every applicable criterion;however, it does not provide specific reference
information to enable easy location of informationwithin the plan for some criteria (for example, A. .d,
A.2.b, and H.3 just reference "Basic Plan"). TheNUREG-0654 Cross Reference is riddled with errors(see report by criterion). Provide an accurate, specific
NUREG-0654 Cross Reference.
Interim.Findings Report For Open Items (North Anna Power Station) - 25 -
RAI Number Open Item Description State/County I/County 2
NA 051 B NUREG-0654 Evaluation Criterion P.8 Louisa CountyThe Louisa County RERP contains both a Table of
Contents and a NUREG-0654 Cross Reference. TheNUREG-0654 Cross Reference is riddled with errors(see report by criterion). Provide an accurate, specific
NUREG-0654 Cross Reference.
NA 051 C SAME AS RAI 051 B Caroline County
NA 051 D SAME AS RAI 051 B Hanover County
NA 051 E SAME AS RAI 051 B Orange County
NA 051 F SAME AS RAI 051 B Spotsylvania CountyNA 052 A NUREG-0654 Evaluation Criterion P. 10 Commonwealth of Virginia
"Updating of Telephone Numbers, Call-Down Lists,and Maps"
The COVRERP, Section IX.B, Responsibilities,Attachment 1 There is no mention of updating call-
down lists or maps as required by GuidanceMemorandum PR-i, Policy on NUREG-0654/FEMA-
REP-i and 44 CFR 350 Periodic Requirements,October 1, 1985. Provide information on thequarterly update of call-down lists and maps.
NA 052 B NUREG-0654 Evaluation Criterion P. 10 Louisa CountyThe Louisa County RERP, Section X,
Responsibilities, states that the Coordinator ofEmergency Services is responsible for the quarterlyupdate of the telephone numbers in the procedures.There is no mention of updating call-down lists or
maps. Provide information on the quarterly updateof call-down lists and maps.
NA 052 C SAME AS RAI 052 B Caroline County
NA 052 D SAME AS RAI 052 B Hanover County
NA 052 E SAME AS RAI 052 B Orange County
NA 052 F SAME AS RAI 052 B Spotsylvania County"
Interim Findings Report For Open Items (North Anna Power Station) - 26 -